Legal
This policy is available in English and Dutch. In the event of any discrepancy between the two versions, the Dutch text prevails.
Keizoku Infra ("we", "us") is committed to protecting your personal data. This policy explains what information we collect through this website and through contact with us, why we collect it, and what rights you have under the General Data Protection Regulation (GDPR / AVG).
Keizoku Infra
Westerstraat 10, 3016 DH Rotterdam, Nederland
KVK: 42107900
Email: contact@keizokuinfra.com
Depending on the nature of our relationship with you, Keizoku Infra acts in one of two capacities under the GDPR/AVG:
Contact enquiries
When you email us at contact@keizokuinfra.com, we receive your email address, your name (if you include it), and the contents of your message. We use this information solely to respond to your enquiry and, where an engagement follows, to perform our contractual obligations.
Website visitors
This is a static website with no contact forms, no user accounts, and no third-party scripts. We do not collect IP addresses, set cookies, or use any analytics or advertising tools. Your visit to this site generates no personal data on our end.
For some clients, we host and operate services that process personal data belonging to that client's own contacts or customers — for example, the people who message a client's business. In these cases, Keizoku Infra acts as a data processor: the client is the data controller, determines the purpose of the processing, and remains responsible for its own legal basis and obligations towards its contacts or customers under the GDPR/AVG. We process this data only on the client's documented instructions, under a data processing agreement (verwerkersovereenkomst) with the client.
Many of our clients — notary practices, law firms, accountants — carry their own strict statutory confidentiality obligations (such as the notary's geheimhoudingsplicht or the lawyer's beroepsgeheim). We select and vet sub-processors with this in mind, and we do not access or use message content for any purpose other than providing and maintaining the service.
Each service we offer is described in its own subsection below. This section will grow as we introduce new service lines; each will get a clearly labelled subsection of its own rather than changing the general terms above.
3.1 WhatsApp Business Inbox Hosting
We host a managed WhatsApp Business inbox (built on Chatwoot Community Edition) that lets a client's team send and receive WhatsApp messages with their own customers through the client's own WhatsApp Business Account.
Sub-processors used for this service:
International transfer note:
Meta is based in the United States. Message delivery through the WhatsApp Business Platform relies on Meta's self-certification under the EU-U.S. Data Privacy Framework (DPF), which the European Commission recognised as providing an adequate level of protection in its adequacy decision of 10 July 2023, supplemented by Standard Contractual Clauses where applicable. The Autoriteit Persoonsgegevens and the European Data Protection Board continue to monitor the DPF's operation, and its validity has been and may again be challenged before the courts. We monitor developments here and will update this section, and our sub-processor agreements, if the legal basis for this transfer changes.
Retention:
WhatsApp message and attachment data is retained for the duration of the client's active engagement with us. Upon termination of the engagement, this data is deleted within 30 days, unless the client instructs us to delete it sooner, requests an export before deletion, or a longer retention period is required by law.
Deletion requests from end-users:
If you have messaged one of our clients over WhatsApp and want to exercise a data protection right (for example, to request deletion of your messages), please contact that client directly — not Keizoku Infra. We do not have a direct relationship with our clients' customers and, as a processor, can only act on the client's instructions. The client, as data controller, is responsible for responding to your request and may instruct us to delete the relevant data accordingly.
This section covers data we hold as controller — i.e. website and enquiry data described in Section 2. Email correspondence related to a client engagement is retained for 7 years following the end of the engagement, in accordance with Dutch tax record-keeping requirements. Enquiries that do not result in an engagement are deleted within 12 months. Retention for data we process on a client's behalf as a processor is set out in Section 3 for the relevant service.
This section covers data we hold as controller — i.e. website and enquiry data described in Section 2. We do not sell, rent, or share this data with third parties for marketing purposes. It may be disclosed to third parties only where required by law. We use standard email infrastructure hosted within the EU, and no other processors handle it. Sub-processors used for services we provide to clients are listed in Section 3.
Where Keizoku Infra acts as data controller — for example, for our own business contacts or website visitor data described in Section 2 — and a government agency, law enforcement body, or other public authority requests that data, we:
Where we process personal data on behalf of a client as their processor under a verwerkersovereenkomst — for example, WhatsApp message data belonging to a client's own customers, described in Section 3 — any such request should be directed to that client directly, who remains the data controller of that data, consistent with how we handle end-user deletion requests above.
Under the GDPR you have the right to:
To exercise any of these rights, email contact@keizokuinfra.com. We will respond within 30 days.
You have the right to lodge a complaint with the Dutch data protection supervisory authority:
Autoriteit Persoonsgegevens
Postbus 93374, 2509 AJ Den Haag
autoriteitpersoonsgegevens.nl
We may update this privacy policy from time to time. The current version is always published on this page, with the date of the last update noted at the top.